20070623 Ver 1_Staff Comments_20070503

NC Division of Water Quality
401 Oversight and Express Permitting Unit
May 3, 2007
Memorandum
To: File
Cyndi Karoly
From: Eric Kulz
Subject: Comments on Mitigation Plan
Little White Oak Creek Restoration Site -Polk County (20070623)
Mulkey Engineering -Full-Delivery Project to EEP
This site looks like a good site for restoration. The site is pasture and cattle have been using the
site for approx. 50 years. The proposed plan involves a combination of priority 1 and priority 2
restoration of a section of Little White Oak Creek (3`d/4th order stream), a section of the South
Branch of Little White Oak Creek (3`d order stream - to its confluence with Little White Oak
Creek), and portions of four 1st order tributaries to these main streams.
I don't have any significant comments on the proposed restoration reaches or methodologies.
My questions/comments arise based on additional features that are not being restored. The
Exec. Summary of the Mitigation Plan states that "The ....site is a large stream restoration and
conservation easement acquisition project to create a contiguous, high quality ecosystem
restoration project.".
However, two stream features within the project site, Reach R1 B (trib. to South Branch of Little
White Oak Creek) and Reach R2C (trib. to Little White Oak Creek) are not being addressed.
Both of these features flow through pastures on the site, both have little to no riparian zone, both
appear to have been channelized (as the other streams proposed for restoration), and it is
presumed that cattle will continue to have access to these features.
Both of these features will continue to flow directly into the receiving streams, both of which are to
be restored. Full of runoff from the cow pastures.
The reason given for not including these features is stated in the Mitigation Plan. In both cases,
these features are "not being considered as originally proposed because the other project stream
reaches provide the total amount of SMUs proposed by Mulkey for this project".
Does not appear to me to be a "contiguous, high quality ecosystem restoration project",
particularly since feature R2C has its origin on the site.
I guess it is all about how many credits are needed.
I have given the file to Periann to 2"d for triage.
North Carolina Division of Water Quality; 401 Oversight and Express Permitting Unit
1650 Mail Service Center; Raleigh, NC 27699-1650
2321 Crabtree Blvd., Raleigh, NC 27604-2260
Telephone: [phone]; Fax: [phone]
http://ncwaterq uai ity. org/wetlands